Baltimore Outer Harbor Crossing Replacement Proposal

The Outer Harbor Crossing was the planning name for the 11-mile-long Baltimore Beltway toll facility between MD-10 and MD-151, and it included the 1.6-mile-long Francis Scott Key Bridge over Baltimore Harbor.

The bridge south main pier was struck by an out-of-control container ship MV Dali on March 26, 2024, and the 2,644 foot long truss structure completely collapsed.

An 8-week period ensued for salvage crews to remove the wreckage and reopen the main shipping channel.

	Key Bridge timeline for collapse and recovery
	March 26, 1:30 am collapse
Mar. 30,31	Large barges with cranes arriving
Apr. 1	Open north temp channel
Apr. 2	Open south temp channel
Apr. 19	Unified Command opens third temporary alternate channel. The Fort Carroll Temporary Alternate Channel, depicted in green, has a controlling depth of 20 feet, a 300-foot horizontal clearance, and a vertical clearance of 135 feet, and will facilitate additional commercially essential vessel traffic through the port of Baltimore. Infographic courtesy of Key Bridge Response 2024 Unified Command.
May 21st	Removed Dali from channel
May 25th	Channel fully open

 

New Key Bridge Design Unveiled (extracted from KeyBridgeRebuild dot com on 8-25-2025)

On February 4, 2025, Maryland Governor Wes Moore unveiled the new design concept for the Francis Scott Key Bridge Rebuild. The governor stated that the new design honors the architectural tradition of the original bridge. The new bridge will be Maryland's first highway cable-stayed bridge, constructed according to the most advanced industry standards and best infrastructure design practices.

Bridge Features

• Two 12-foot lanes in each direction / 10-foot-wide outside shoulders and 4-foot-wide inside shoulders per direction of travel  

• Total Bridge length more than 2 miles  

• 230-foot minimum clearance from water to bridge deck above the federal channel

• Two bridge towers more than 600 feet tall

• Distance between main span pylons exceeding 1,600 feet 

• Total length of cable-stayed main span exceeding 3,300 feet 

• Expected life span of 100 years

This rendering has been on their website main page and banner of their Facebook page for the rebuild project for at least since early-2025:

The main piers including those concrete tubs are only about 150 feet farther from the shipping channel, and the south main pier is in waters 35 feet deep at mean high water (see the revised USCG permit plan view).

 

The real issue: MDTA's PR blunder in showing a cable-stayed bridge without the promised ship-collision protection system. Fenders or dolphins should've been in the concept to reassure the public post-Dali. It's not about final plans -- engineers are still studying -- but leaving out safety visuals is tone-deaf. This isn't a scam, just a dumb oversight.

FHWA Categorical Exclusion issued for environmental document.
PUBLIC NOTICE D05PN-02-2025 was issued by the U.S. Coast Guard and has the permit information for the design chosen by MDTA.

The purpose of this website article is to evaluate the proposal of the Maryland Transportation Authority (MDTA) and to recommend alternatives.

I oppose their plans for this project, as having the same vulnerabilities as the original bridge, and having constricting effects on future of the harbor.

MV Dali details and initial probable cause of incident

The MV Dali is a 984-foot Neopanamax container ship weighing 116,851 deadweight tons and capable of carrying nearly 10,000 TEUs. On March 26, 2024, while departing Baltimore en route to Sri Lanka, the vessel suffered a sudden electrical failure that disabled its propulsion and steering systems. The blackout occurred at 1:29 a.m., just as the ship approached the Francis Scott Key Bridge. With no ability to maneuver, the Dali drifted into a critical support pier, triggering a catastrophic collapse that killed six construction workers and severed a vital artery of Interstate 695.

Investigations revealed that a loose wire in the ship’s control circuitry caused the power outage, and the vessel had a history of vibration issues and prior collisions, including one in Antwerp in 2016. The U.S. Coast Guard classified the incident as a major marine casualty, and the National Transportation Safety Board (NTSB) launched a full investigation. The ship was temporarily repaired in Norfolk before undergoing extensive rehabilitation in China. Legal claims exceeding $100 million have been filed, and the event has sparked renewed scrutiny of maritime safety protocols and infrastructure vulnerability. The Dali’s return to service underscores both the resilience of global shipping and the unresolved risks of large-vessel navigation near critical infrastructure.

MV Dali was traveling at approximately 10 miles per hour, which converts to about 8.7 knots, just before the collision with the Francis Scott Key Bridge. After impact, the vessel slowed to around 7.8 mph (roughly 6.8 knots) as it absorbed the force of the crash and came to rest against the wreckage. Given the bridge’s original design and materials, it’s reasonable to estimate that 15,000 to 20,000 tons of wreckage ended up on, around, and blocking the MV Dali.

The 2,644-foot continuous steel truss of the Francis Scott Key Bridge likely weighed between 30,000 and 35,000 tons, this includes the massive triangular framing, gusset plates, and lateral bracing that spanned the Patapsco River.  The reinforced concrete roadway deck, including rebar, asphalt overlay, parapet barriers, and embedded utilities, adds another 60,000+ tons. With an estimated deck width of ~85 feet and thickness of 8–12 inches, the concrete alone contributes tens of thousands of tons, and the steel reinforcement and surface layers compound that total. Together, the bridge’s superstructure likely weighed 90,000 to 95,000 tons, making it one of the heaviest continuous truss spans in the U.S.

How big is 100,000+ tons?

Such large numbers can seem academic and hard to visualize.

To give readers how much 100,000 tons is, consider this -- the massive Cape Hatteras lighthouse weighs about 5,000 tons aboveground and about 1,000 tons below ground.

If it was out in open waters, what do you think would happen if a 100,000+ ton ship hit it while sailing at 10 knots?

Attacks on the structural design of the bridge

Almost immediately some internet experts started blaming the design of the bridge, saying that it was "weak, fragile, fracture critical, etc." and that it should have been able to absorb the hit and remain standing.

The bridge didn't have a fracture critical issue. Despite what some internet posters including one supposed civil engineer on YouTube kept claiming. The definition of fracture critical basically means that the failure of one subordinate (secondary) member will cause a massive failure of the whole bridge. Like the pin-and-hanger design on the I-95 Mianus River bridge and others whereby the failure of one beam hinge connector will lead to the collapse of the entire bridge. That is a fracture critical bridge.

The Key Bridge didn't rely on every truss beam being intact. I don't know what the exact number is but at least one could be removed without the failure of the entire truss. The important word is "fracture" which suggests a crack and not a massive destruction. Knocking out a main support pier on a long span bridge is not a fracture, it is a disaster that will cause the entire span to disintegrate.

How do you explain to someone the amount of kinetic energy at work here and what it can do? Some 9/11 Truthers say that since an airliner is largely made out of light aluminum structures and that the Twin Towers was a steel structure, that the plane should have gone "splat" on the side of the building with little or no penetration.

That of course is baloney any way you slice it -- you have a 150 ton object moving at 500 mph (the speed of a 45 auto pistol bullet) and it did enormous damage to the building. A 150 ton water balloon (if such a thing was possible) would likewise do enormous damage to the building. An EF5 tornado is in the 180-220 mph range and it can rip house foundations and basements right out of the ground. And that is nothing but wind. Imagine what a 500 mph tornado would do?

The Key Bridge was a continuous truss with multiple load paths. It could tolerate localized member failure. What it couldn’t survive was the obliteration of a main support pier, a foundational element, not a subordinate one. That’s not a fracture. That’s a structural amputation.

The MV Dali weighed 116,851 metric tons and was moving at 8.7 knots (~10 mph). That translates to roughly 1.6 billion joules of kinetic energy, comparable to the explosive force of 900 pounds of TNT. No bridge designed in the 1970s (if ever) was built to absorb that kind of lateral impact to a critical pier.

To visualize it: A 150-ton aircraft hitting a steel skyscraper at 500 mph isn’t just aluminum vs. steel, it’s momentum vs. resistance. The plane doesn’t need to be dense; it needs to be fast. A 150-ton water balloon at that speed would still pulverize a structure. Mass × velocity² is unforgiving. An EF5 tornado, at just 200 mph, can rip homes from their foundations. Now imagine a 500 mph wind, or worse, a solid object moving at that speed.

The Dali didn’t hit a truss beam. It hit Pier 17, which supported the main span. Remove that pier, and the span has nowhere to go but down. The collapse wasn’t due to a crack propagating through steel, it was due to the instantaneous loss of vertical support. That’s not fracture critical. That’s support critical.

The Dali’s impact wasn’t just about raw energy -- it was about momentum, structural vulnerability, and instantaneous load transfer. The bridge didn’t absorb a blast -- it absorbed a moving wall of steel with the mass of 2,900 loaded tractor-trailer trucks. That’s not a fracture. That’s a blunt-force amputation.

Key Bridge conceptual rebuild alternatives as of March 2024 -- per Roads to the Future

1. Replace the 2,644 foot long main span structure, the part that collapsed. Use a cable stayed or cantilever structure. Replace the three plate girder spans on the north approach that also collapsed, 895 feet total: south to north - 285, 290, 320. Same cross section as existing bridge. This alternative may be buildable for the $400 million minimum that has been cited in news sources, we will need to see a detailed engineering estimate.
2. Similar to Alt. 1 except the new spans will have 10 foot right shoulders.
3. Similar to Alt. 2 except the pre-existing approach spans will be widened to have 10 foot right shoulders.
4. Replace entire bridge on the same alignment, with maximum 2.5% grades. This will be a longer bridge and it will have 10 foot right shoulders.
Issue: several recently built bridges over shipping channels have vertical clearances in the 215 foot range. That is 30 feet more than the Key Bridge and such a bridge would have a higher profile than the entire original bridge and would necessitate replacing the entire original bridge.
5. Remove pre-existing bridge structures, build approach roadways on causeways (that were built for the original tunnel plan) Build 6,200 foot long twin-tube 4-lane tunnel under harbor.
6. No build. Remove remaining bridge structures.

Given the flat traffic growth that has basically been stable at about 31,000 AADT since 2006, 4 lanes (2 each way) should be adequate for the design year of 2045.

I would like to see the tunnel funding be explored. I know it would be expensive but I see it as the only proper solution (other than not building any new crossing at all and letting traffic be handled on the inner harbor tunnels and their freeways).

A large enough island/dolphin system for a bridge would undoubtedly cause hydrologic problems. I really don't think it is possible to protect against ships of this size. They could build an island 1,000 feet in diameter but then in that about 5,200 foot opening it would interfere with water flows and that river is tidal there. Resource agencies tasked with environmental approvals would almost certainly oppose such a design and refuse to approve it.

My solution would be a tunnel as on the Chesapeake Bay Bridge-Tunnel and the I-64 Hampton Roads Bridge-Tunnel and I-664 Bridge-Tunnel

I-664 Monitor-Merrimac Memorial Bridge-Tunnel, Newport News, Virginia

MMMBT never will block a main shipping channel, and will be good to go in 2090 and maybe beyond.
The original I-64 HRBT opened in 1957 and is no danger of ever becoming nautically obsolete.

This one spans the entire water body, with 4,619 foot long main span, no piers in the waters.
Yavuz Sultan Selim Bridge (Third Bosphorus Bridge), hybrid cable-stayed suspension bridge, 210 feet of vertical navigational clearance.

I could cite all three of the Bosphorus Strait bridges in Istanbul, Turkey -- with no piers in the water (well actually one is in waters near the shore about 4 feet deep) -- no danger from ship strike.

Here's a list of the main span lengths of the three Bosphorus Strait bridges in feet:
+ 15 July Martyrs Bridge (First Bosphorus Bridge): 3,524 ft
+ Fatih Sultan Mehmet Bridge (Second Bosphorus Bridge): 3,576 ft
+ Yavuz Sultan Selim Bridge (Third Bosphorus Bridge): 4,619 ft

They also have a downtown highway tunnel and a downtown railroad tunnel under the strait -- those folks don't play -- they mean business!

The Baltimore Outer Harbor Crossing approach tunnel portal causeways are already in place

That was the original plan there and the causeways projecting from shore were intended to have the tunnel portals for a single-tube two-lane 6,200-foot-long harbor tunnel. The two-lane freeway was placed under construction, the causeways (landfill for roadway across a water body) for the tunnel portals were built, and when the tunnel was advertised for construction in 1970, the bids received on July 30, 1970 were so high that it was determined that a four-lane high-level bridge could be built for about the same cost as the revised estimate for the tunnel project.

The causeways are wide enough to accommodate a second tunnel tube.

South Causeway (click them for large image)	North Causeway
Images showing line of original shoreline before construction of causeways in the harbor in 1970 for tunnel project	Images from Google Maps Satellite View

See original Roads to the Future article Baltimore Outer Harbor Crossing (Key Bridge) for cites.

Some internet roads forum poster claimed in May 2025 --
"There has been a lot of misinformation put out that says that no bridge could be adequately protected from damage or destruction from impacts due to striking cargo ships or barges."

It is not misinformation.

The number and size of dolphins needed to protect bridge piers from a 1,000 foot long heavily loaded ship moving at 10 knots, might not even be feasible without imposing unacceptable hydrological impacts on water flows.

I have reviewed 10 such bridges in the U.S. and none of them provide more than 150 feet of protection, and the bow overhang and speed would destroy that and sever the tower, leading to the collapse of the entire suspended span.

A vessel that size and speed would either ride over the island and through the piers, or would rip the entire structure from the bottom of the bay. The only actual solution I can see is to tunnel under the shipping channel, so that there is no bridge there in the first place. Like the bridge-tunnels in the Norfolk, VA, USA area.

Baloney is a reserved word on the Internet
(Robert Coté, 2002)

My solution would be a tunnel as on the Chesapeake Bay Bridge-Tunnel and the I-64 Hampton Roads Bridge-Tunnel and I-664 Bridge-Tunnel. No bridge over the shipping channel that can be hit by ships or bombed during war.

The I-695 approach tunnel portal causeways are already in place, for the original design. MDTA planned a 6,200 foot long tunnel but advertised for bids and found that the bridge could be built for half the cost. Shame -- the tunnel would still be in operation today.

I was always a skeptic about the need for those Hampton Roads and Chesapeake Bay tunnels, based on U.S. Navy requirements. Based on the history of war I cannot envision any means for a conventional attack to destroy the bridge. A nuclear attack would destroy the entire port area so bridges falling are moot. Tu-95s and sub-launched cruise missiles would not be identifiable as non-nuclear until the warheads detonated, so conventional bombs used on them don't really make sense.

I favored any new capacity to be provided on a high-level bridge. Now with this incident and the ramifications of super-ships using the ports, and frequently, I have completely reversed my stance.

However, they could span the entire 5,150 distance between the two causeways with the main span, along the lines of the Bosphorus Strait bridges, and not place any bridge piers in the waters. This is a viable alternative.

HRBT Expansion High-level Bridge Crossing Alternative considered and rejected

HRBT High Bridge Crossing

The high bridge alternative would involve a new cable-stayed or suspension bridge parallel to the existing  HRBT over the Hampton Roads channel. The bridge would be built to carry a sufficient number of lanes of I-64 over Hampton Roads to address the capacity need. This alternative would fully address the geometric deficiencies of the existing HRBT facilities by constructing a new bridge that would have full shoulders, no vertical clearance issues, and meet or exceed the minimum height above mean high water (MHW).

However, a high bridge creates logistical challenges in terms of shipping and military vulnerability, and presents environmental impacts that a tunnel does not. Although a high bridge over Hampton Roads could be a feasible alternative from an engineering perspective and would address the stated transportation needs, the alternative created additional problems that made it unreasonable to retain.

From the Hampton Roads Crossing Study - Draft Environmental Impact Statement, October 1999, page 19, above is the Virginia Department of Transportation (VDOT) citation as to why the Hampton Roads crossings over major shipping channels are tunnels and not high-level bridges.

High Level Bridges

High level bridges were considered for all of the Transportation Corridors crossing Hampton Roads, but were eliminated from further study. A high-level bridge crossing near the Hampton Roads Bridge Tunnel or at the Elizabeth River crossing would conflict with the required clear zone of the Norfolk Naval Air Station. Also, the Navy historically has opposed a high level bridge over channels used by their ships in the Hampton Roads area.

Additionally, concern has been expressed by the Hampton Roads Maritime Association that a high level bridge may limit ship size and hinder future access to the ports of Hampton Roads. There was general concurrence from the Hampton Roads Crossing Study Coordinating Committee to eliminate high level bridges from further detailed study.

Above from the Hampton Roads Crossing Study - Draft Environmental Impact Statement, October 1999.

Excerpt from I-664 Location Hearing Information brochure, which was distributed to the public by the Virginia Department of Highways, for the Location Public Hearings which were held March 13 and 14, 1973, on the north and south sides of Hampton Roads respectively:

A bridge-tunnel water-crossing was selected after preliminary studies as being superior to a high-level bridge crossing for national defense, navigational, and esthetic reasons. National defense reasons militate against a bridge because of the paralyzing effects on access to the Navy storage and shipbuilding yards should the bridge be severely damaged by enemy attack and dropped into the channel. A bridge will also be very prominent when elevated sufficiently to give adequate vertical clearance for shipping, and the approach grades on the north side will have to begin a mile or more from the shoreline to conform with Interstate design requirements.

Typical opposition talking points against tunnels

Claim: They cost far more than a bridge.

Response: The tunnel wouldn't necessarily cost more. A bridge with 2020s standards for vertical navigational clearance (VNC) and approach grades would have 230 feet of VNC and be about 2.5 miles long.

The tunnel would be 6,200 feet long, and the land roadway to be built would be about 1,800 feet on either side. Land roadway construction is much lower in costs than bridge construction.

I want the highway agency to provide detailed engineering cost estimates for each. I am reaching out to both MDTA and FHWA concerning this.

If MDTA had built the original tunnel plan for the Outer Harbor Crossing, we would not have a major deep water port blocked for 8 weeks, with several billion dollars of economic losses, and $2 billion needed to restore the highway crossing.

Claim: Bridge protection schemes will protect the bridge -- the photos of the Sunshine Skyway are frequently shown, and it has "dolphins" and small islands around the major piers.

Response: None of those bridge protection schemes has ever been tested with a MV Dali type event. Such "protections" have not been tested in real world tests or events.

Unless you ram a 200,000+ tons ship head-on into that tower island at 10 knots, you will not know whether it will survive the test.

Civil engineering works need to be tested, to assure that they perform to specs.

It is like if the USAF accidentally dropped an atom bomb on a populated area in the U.S. and it detonated. Some things are so critical that you -cannot- make even one mistake.

On average, the Port of Baltimore sees about 2 to 4 gasoline tanker ship arrivals per day, and they carry between 20,000 and 60,000 tons of gasoline depending on the load, and all their docks are upstream of the Key Bridge. If one crashed into the bridge and/or dolphins and the hull tore open and the cargo caught fire it would be a very bad day.

Secondary consequences of a major strike
+ Hazardous material spill: A ruptured tanker or container ship could release flammable, toxic, or reactive cargo directly into the channel, creating both environmental disaster and navigational closure.
+ Fire and thermal load: A prolonged blaze aboard ship or ignited cargo -- especially under a cable-stayed span with polymer sheathings and tensioned steel -- could compromise structural integrity through heat-induced deformation or cable creep. This could cause the suspended spans to collapse even though not impact damaged.
+ Bridge closure: Even non-collapse damage could mean months of forensic inspection, partial reconstruction at hundreds of millions of dollars, and economic disruption, not to mention rerouting 32,000 vehicles daily.

Limitations of pier protection
+ Deceleration assumption: The idea that a vessel at 10 knots and ~200,000 tons can be safely "caught" by sacrificial concrete or steel dolphins is a fiction born of modeling -- not real-world validation.
+ Shock transfer: Impact forces don't just stop at the barrier -- they travel into the foundations, into the superstructure, and sometimes into the vessel itself, creating debris fields and multi-system failures.
+ No fire suppression integration: Unlike tunnels, these systems typically have no integrated fire containment, leaving responders to deal with open, unshielded conflagration next to steel infrastructure.

The false promise of "deflection" -- What's being sold as protection is, in reality, impact redirection with untested collateral. It's akin to installing crash barriers on a runway and assuming that'll prevent an aircraft from causing damage during a failed takeoff -- without factoring in fuel, fire, or kinetic fallout.

The idea that only Dali-scale ships pose a threat is a convenient fiction. A 50,000-ton vessel moving at 15 knots -- even if drawing just 25 feet -- still carries enough kinetic energy to inflict catastrophic damage on a bridge pier not designed for modern impact loads.

The physics of a "non-Dali" Strike
+ Kinetic Energy (KE) scales with mass × velocity², meaning velocity is the real multiplier. A ship going nearly twice as fast as the Dali has roughly 4× the impact energy, even if it's half the mass.
+ A Panamax bulk carrier, at 50,000–60,000 DWT and 25-foot draft, is common in U.S. ports and perfectly capable of traveling at or above 14-15 knots in fairway conditions.
+ Unlike container ships with elevated bridge visibility, many bulkers have more challenging sightlines and slower rudder response -- amplifying collision risk during navigational error or control loss.

Designing protection systems around "worst-case" Dali-scale impacts ignores the reality of higher-speed, medium-mass vessels, which can deliver destructive force with greater probability.

An internet roads forum poster ralphed this out:
" If building a bridge cost half as much as building a tunnel back then .."

I replied:
Highway contract bids can vary widely based on various economic factors and local factors. As much as I admired the Key Bridge, there were major compromises made in its design. The grades are steep at 5%. Should have a climbing lane for large trucks. The bridge lacks emergency shoulders. Overall length, profile and cross-section were substandard even for a 1970s Interstate highway design. There are three 2-lane tunnels under construction in the Hampton Roads area that are longer than 6,200 feet and cost under $900 million each.

National Environmental Policy Act (NEPA) -- Environmental Impact Statement (EIS)

I am not at all satisfied with the process being utilized here, whereby MDTA announced an RFP for a new bridge by the end of May 2024.

I have my opinion on what alternative should be selected, but the most important thing is to engage the public and the associated resource agencies, and to lay out the alternatives before them and then to make an informed decision by the highway agencies.

Conduct full NEPA EIS process
1) State highway agency prepares Draft EIS -- compile comments from associated resource agencies, prepare a full range of feasible alternatives, evaluate environmental impacts
2) State highway agency conducts public hearings where alternatives are presented, with a public comment period.
3) State highway agency selects preferred alternative
4) State highway agency prepares Final EIS
5) FHWA approves or disapproves Final EIS
6) State highway agency prepares Record of Decision
7) FHWA approves or disapproves Record of Decision

The ship collision and bridge collapse in and of itself is a catastrophic event to both the natural environment and the human built environment.

Building a replacement crossing that will prevent such events in the future, is also relevant to protecting the natural environment and the human built environment.

Therefore I strongly urge that FHWA require a full NEPA EIS on the project.

National Environmental Policy Act (NEPA)
Environmental Impact Statement (EIS)

NEPA requires Federal agencies to prepare environmental impact statements (EISs) for major Federal actions that significantly affect the quality of the human environment. An EIS is a full disclosure document that details the process through which a transportation project was developed, includes consideration of a range of reasonable alternatives, analyzes the potential impacts resulting from the alternatives, and demonstrates compliance with other applicable environmental laws and executive orders. The EIS process in completed in the following ordered steps: Notice of Intent (NOI), draft EIS, final EIS, and record of decision (ROD).
-- Copied from FHWA website

I have had this discussion with at least a dozen different people in various internet forums, and it seems like I am talking to the same person every time.

The same points, the same words like "hazmat, dolphin, protection," etc. The same adamant refusal to understand the rationale for a tunnel.

HRBT Expansion is a single $3.8 billion master contract, but that is for 9 miles of I-64 8-lane widening and 22 bridges. Four of those bridges are replacement trestles on the bridge-tunnel itself, and two of those bridges are widening the Willoughby Bay Bridges. So six of the bridges are large.

They don't have a detailed breakdown on their website, but the best I can determine is $1.9 billion for the two new 7,900 foot long 2-lane tunnels. That is 28% longer than the Outer Harbor Tunnel.

MDTA has failed to inform the public about a set of alternatives and the estimated cost for each. It would take a detailed engineering estimate to determine the cost of the tunnel. I would like to see a professional estimate and they have not provided that.

It looks doable in 4 1/2 years but if it takes longer then the important thing is to do the job right even if were to take longer and cost more.

Tunneling is not expensive when the alternative is a $2 billion bridge that is vulnerable to ship strike and destruction.

The Sollers Point location is not a safe place to build a bridge similar to the old one in span lengths. The risks are catastrophic as we have just seen.

Reasonable and prudent alternatives, so that there are no deep water piers that can be hit by superships.
1) Build a bridge with a 5,200 foot long main span between the two causeways
2) Build the original 6,200 foot long tunnel design between the two causeways
3) No-Build Alternative
If they are not willing to select Alternative 1 or 2, they should select Alternative 3.

Estimate for an Outer Harbor Tunnel

Two major shipping channels are crossed by the Chesapeake Bay Bridge-Tunnel.

The 5,738-foot-long Thimble Shoal Channel Tunnel crosses the southerly channel used by Hampton Roads ship traffic.

The Parallel Thimble Shoal Channel Tunnel Project is under construction and costs $755 million for a 2-lane tunnel.

I think it is reasonable to make a preliminary estimate for a twin-tube 6,200 foot Outer Harbor Tunnel, with two lanes in each tube, at $1.5 to $1.6 billion.

That is less expensive than the $1.7 to $1.9 billion estimate for the MDTA cable-stayed alternate.

The Thimble Shoal Channel is 1,000 feet wide and 50 feet deep. There is an auxiliary channel 450 feet wide on each side of the main channel and they are maintained at 30 to 35 feet deep. So 1,900 feet width of deep water shipping channel. The CBBT Thimble Shoal Tunnel passes beneath this channel.

The Hampton Roads Bridge-Tunnel crosses a naturally deep area with 55+ foot depths at for at least 3,000 feet wide. See NOAA Chart Hampton Roads 12245 for each of the above.

As far as protecting bridges, nothing is impossible but the key thing is to assess risk and reduce risk.

Is there some kind of internet bot that immediately injects the words "hazmat" and "dolphin" into internet forum discussions about this topic?

Hazardous Materials (HAZMAT) Truck Shipments

Concerning all this talk about HAZMAT that constantly comes up on various forums that discuss this bridge. The best data I can find is that the Key Bridge AADT (Annual Average Daily Traffic) was about 32,000 with 10% large trucks with about 10% of the shipments being HAZMAT material that MDTA won’t allow thru the tunnels.

So about 350 to 400 shipments per day. To me that is very little justification for spending $2 billion to avoid tunnels; granted there were the other 31,000 vehicles. But the two Interstate highway cross-harbor tunnels carry the 225,000 AADT now and have a total of 12 lanes.

That is about the same AADT as the I-495 American Legion Potomac River Bridge (which actually is about 235,000) which has 8 thru lanes. The Key Bridge had 1/7 of that traffic and Maryland is doing nothing to expand the ALB and the rest of I-495 between VA and I-270 to the VA 12-lane cross-section (4-2-2-4) with HOT lanes.

Modern era tunnels are designed to allow hazardous cargos. Many world ports don't allow bridges across shipping channels and there needs to be a way to transport those highway cargoes.

I could and may take the time to list all the major ports that have no bridge between the deep water port and the ocean. A few --
Hamburg (tunnel), Copenhagen (tunnel between city and entire Baltic Sea, no crossings between the city and the ocean), Rotterdam (tunnel), Tokyo (bridge-tunnel) and Osaka immediately come to mind.

The Tokyo Bay Aqua-Line (東京湾アクアライン) is a 8.9 mile long bridge-tunnel and the tunnel is 5.8 miles long. It crosses Tokyo Bay between the ocean and the deep water ports in the upper bay. Tokyo has 9 short highway underwater tunnels and virtually all of the inner harbor and river docks are accessible from the ocean without passing under a bridge.

The VA I-664 Monitor-Merrimac Memorial Bridge-Tunnel (MMMBT) was designed with the clearances and safety systems so that nearly all hazardous materials can use it, including RVs with standard propane tanks, including gasoline tanker trucks. That was opened in 1992.

An outer harbor tunnel could likewise be designed with the clearances and safety systems to handle nearly all hazardous materials.

There is another factor -- some of those complaining on internet forums are not truckers but are private operators of RVs and with the standard propane tanks they are not allowed to use the Baltimore tunnels.

Virginia handles that by allowing them in all tunnels even the oldest -- each has an inspection area before the tunnel whereby any hazmat vehicle is required to stop for inspection. If they fail there is a ramp from the inspection area to the closest major surface road.

You must ensure that your propane tanks are completely shut off before entering the tunnel. There are inspection stations where you can stop to turn off your propane tanks. It's crucial to follow these rules as there are enforcement measures in place, and failure to comply could result in fines.

Inspection Stations -- Before entering the tunnel, there are designated areas where you might be inspected. The process involves verifying that your propane tanks are off and that there are no leaks. Sometimes, an inspector might physically check, but other times, signaling that the tanks are off might suffice. It only takes a few minutes.

Is this loss of the bridge an emergency?

Building a new outer harbor crossing is not an emergency priority or even a high priority.

I-95 and I-895 and I-695 West are handling the traffic better than typical Washington Beltway traffic in Maryland.

There is ample time to spend at least 6 months on location and design studies to have time to look at the alternatives.

As far as people and logistics companies relying on the crossing, well, that is severed for at least 48 months and by then those systems will long since have been reconfigured.

The Elizabeth River Tunnels project was on time and on budget. That involved a building a Parallel Midtown Tunnel, extending the MLK Freeway to I-264, and large scale renovations of the three older tunnels.

Some bridges wind up hopelessly behind schedule and over budget, SFOBB eastern span for one. The original Key Bridge was behind schedule.

I have sent detailed e-mails to MDTA and FHWA Maryland Division, and they have been non-responsive.

The tunnel approaches are already built as the above photo shows.

They just proved that the Sollers Point site is unsuitable for a bridge.

The combination of underwater topography there and the frequent passage of ships up to 200,000+ tons.

Putting up another bridge there is irresponsible and that one may get knocked down as well.

Like I said, there is some kind of emotional reaction going on in Maryland and it is ignoring NEPA and sound engineering and transportation planning principles.

So what if a 74,000 ton ship comes charging up the Delaware River at 17 knots like the recent bridge mishap in Charleston SC, and veers toward the main piers?

How do you convince me as Mr. Taxpayer that this $95 million project will prevent the ship from knocking down the towers?

That the ship won't smash thru the pylons or rip them right off the floor of the river?

A 74,000 ton ship at 17 knots is an incredible amount of kinetic energy.

Funding a new crossing

So who is going to pay for it? The state is requesting 100% federal funding to replace the Key Bridge, above and beyond regular federal aid allocations. If they get it then are they going make it toll-free?

Why should they get any large percentage of federal funding?

I-64 HRBT Expansion (to 8 lanes) is getting about 5% federal funding for a $3.8 billion project. Its general purpose lanes will the toll-free.

Bogus process. The FHWA Maryland Division is as compromised as the state government.

One of my communications to MDTA:
1) You have not engaged the public and had any discussion about what type of bridge (as in length of main span, vertical clearance), and whether a tunnel would be safer and less expensive, or whether it is worth $1.9 billion to build any crossing there.
2) Where is that funding coming from? The state is requesting 100% federal funding, above and beyond regular federal aid allocations. If they get it then are they going make it toll-free? Why should they get any large percentage of federal funding?
3) I live in Virginia but #2 is definitely my business when federal tax dollars are involved. Besides I have family in Maryland.
4) I have described how NEPA EIS location studies operate. In today's world, both tunnel and bridge alternatives, and no-build alternatives, should be analyzed and evaluated in that process so that the public and the agencies can make the best decision.

Just because the FHWA Maryland Division is letting you get away with a CATEX doesn't mean that you are not running a bogus process.

In Maryland of all places with their past reputation for environmental sensitivity. Shameful.

You should conduct a full NEPA EIS.

They have a design-build contract issued as of mid-2024 and they are just now finishing the design in mid-2025.

As far as funding, that is the real scandal here. A sweetheart deal between a Democrat president and a Democrat-run state. Nobody else has ever gotten a deal remotely like this.

Joe Biden made a verbal promise in March 2024 to provide 100% federal funding for replacing the collapsed bridge, at $1.9 billion -- over and above and beyond normal federal aid highway allocations to the state.

It appears to have been written into the omnibus federal spending bill, when his party had a majority in the Senate. A regional bridge with no national importance.

Here are the problems: 1) This was a toll revenue bond supported bridge built in the 1970s without federal aid funding, 2) They want the new bridge to have the same toll, 3) Federally funded Interstate highways are historically prohibited from having a toll, 4) $1.9 billion is an extremely expensive bridge.

Joe Biden shouldn't have made promises like that, the next day, without knowing anything about the facility such as it being a tollroad and not a federal aid highway, without understanding highway funding in general, making stupid comments about how he rode the train over the bridge, without knowing how completely out of step that promise would be historically, without out the appearance of it being largesse to a fellow state. His party had a one-seat majority in the Senate where the omnibus bill originated. The whole process stinks like vomic.

He had been in office for 3 1/2 years at that point, and his appointments for federal agency heads had been in place for that length of time, and they set the tone for what that agency does. This includes FHWA as a whole, FHWA Maryland Division, USCG and ACOE. Each of these entities plays a gatekeeping role in infrastructure visibility, permitting, and strategic alignment.

Strategic implications of entrenched appointments
FHWA (Federal Highway Administration) and FHWA Maryland Division
+ The Maryland Division serves as the federal interface for state-level transportation planning, project approvals, and funding oversight.
+ By 2025, its tone was shaped by long-standing appointees who influenced:
+ Corridor preservation logic
+ Environmental review thresholds
+ Discretionary grant alignment with federal priorities
U.S. Coast Guard (USCG)
+ Under Admiral Kevin E. Lunday’s leadership (as of Jan 2025), the USCG emphasized:
+ Operational presence and fentanyl interdiction over infrastructure coordination
+ Leadership development framed around “wholistic collaboration” and “team culture”, replacing prior inclusivity language
+ This shift in tone affects how the Coast Guard engages with bridge permitting, navigational clearance, and interagency coordination.
Army Corps of Engineers (ACOE)
+ Led by Lt. Gen. William H. “Butch” Graham Jr. and a reshaped leadership team, the Corps adopted a resilience-focused leadership framework emphasizing:
+ Enterprise-wide perspective
+ Coalition-building
+ Strategic thinking as a formalized competency
+ These appointments influence how the Corps handles Section 408 reviews, floodplain logic, and visibility of relocation alternatives.
This marks a convergence of tone-setting authority across federal infrastructure gatekeepers.
+ Entrenched leadership as tone-setters
+ Federal agency posture shaped by long-term appointments
+ Visibility bias embedded in discretionary review logic

As I said before this was a sweetheart deal, greased thru these federal agencies for approvals and permitting, at the federal level by Joe Biden and his administration, and rushed to take place in 2024 so as to try to lock them in just in case his party loses the presidency and Senate majority in the 2024 election, and the new administration decides to cancel the deal and start over. The state was in sync and partnered with this whole debacle.

There are processes in place whereby state and federal agencies could decide what to do in such a case. Not have the president immediately jump in with his ideas.

I am fine with this being addressed with a legitimate legislative process in the current Congress where a standalone bill can be considered as was in the case of I-35W bridge. Perhaps consider a federal share of 50% which would be a billion dollars and far greater than anyone has gotten before.

I-35W bridge collapse in Minneapolis

I have already considered the I-35W bridge in this whole matter -- it keeps coming up in comparative discussions on internet forums.

The I-35W St. Anthony Falls Bridge in Minneapolis, Minnesota, has an Annual Average Daily Traffic (AADT) of approximately 140,000 vehicles. This figure reflects its importance as a major transportation route in the region.

The cost to rebuild the bridge after its tragic collapse in 2007 was approximately $234 million. The reconstruction was completed using an accelerated design-build process, allowing the new bridge to open to traffic in September 2008, just over a year after the collapse. The bridge has a total length of 1,907 feet, and its longest span measures 456 feet. The bridge is 10 lanes wide. That bridge is a concrete box girder design, spanning across the Mississippi River, and it carries a high volume of traffic, around 140,000 vehicles per day before the collapse. The rapid timeline and relatively modest cost (adjusted for inflation, roughly $330 million in 2025 dollars) were possible due to expedited permitting, a straightforward design, and a focus on restoring a critical urban artery.

This is a far smaller and far less expensive bridge than the Key Bridge and with far higher importance and volume. The logistics of replacing it were about an order of magnitude less than that of the outer harbor crossing.

Minnesota did receive 100% federal funding for the I-35W bridge rebuild, but only after Congress took extraordinary legislative action to override the usual caps. Public Law 110–56, passed in August 2007, explicitly authorized $250 million for the I-35W bridge reconstruction. It waived the $100 million cap normally imposed by the Emergency Relief (ER) program under 23 U.S.C. §125. It also stated: "The Federal share of the cost of the project carried out under this section shall be 100 percent."

The ER program typically reimburses up to 90% for Interstate projects and 75% for non-Interstate routes. Congress had to pass a special law to make the I-35W funding 100% -- it wasn't automatic. The final federal outlay was $183.5 million, with additional funds authorized but not fully spent.

So yes, Minnesota got 100% -- but only through a rare legislative carve-out, not through standard DOT channels. That's what makes the Key Bridge funding even more extraordinary: it was pledged at 100% without a standalone bill, and embedded in a broader spending resolution.

The I-35W bridge replacement is the largest such emergency federal funding so far, and that was only $234 million and that is a toll-free 10-lane urban Interstate highway in a large city.

Maryland wants their cake and to eat it too -- the aforementioned federal largesse, and to keep tolling the bridge as before!

Why the huge cost difference? Several factors stand out. The Key Bridge’s length is over four times that of I-35W, and its steel truss design is more complex and material-intensive than a concrete viaduct. Construction costs have also risen significantly since 2007, labor, materials (especially steel), and regulatory compliance all add up. The new Key Bridge is planned to have a higher vertical clearance (230 feet vs. the original 185 feet) to accommodate larger ships, which extends the approaches and increases engineering demands. Plus, rebuilding over a busy shipping channel like the Patapsco River complicates logistics compared to the I-35W’s river crossing.

As for federal funding, the I-35W project did get 100% coverage through a special congressional appropriation, bypassing the usual 80% federal share under the Federal Highway Administration’s Emergency Relief (ER) program (with states covering 20%). For Key Bridge, the Biden administration and Maryland lawmakers pushed for 100% federal funding too, citing its national economic importance due to the port. In December 2024, Congress passed a spending bill that reportedly includes full funding for the $1.9 billion rebuild, wrapped into a $100 billion disaster relief package. This isn’t just ER funds (which have a $890 million balance against a $2.1 billion backlog); it’s a bespoke allocation, much like I-35W’s.

The government’s promise to recoup funds via insurance and litigation against the ship’s owner might offset taxpayer burden, but that’s a slow process and not guaranteed, plus international maritime law may limit that to about $100 million or about 5% of the cost of a new crossing.

In short, 100% federal funding isn’t unprecedented, I-35W got it too, but the dollar amount for Key Bridge reflects a bigger, costlier project in a pricier era. Whether that $1.9 billion holds up under scrutiny or balloons further will depend on execution and transparency as construction unfolds.

What do you think -- does the economic argument for the port sway you, or do you see this as overreach?

CATEX Document

FHWA Categorical Exclusion issued for environmental document.

I looked at the CATEX document.
+ They got it right with four lanes (2 each way).
+ Average daily traffic has been flat at about 32,000 since 2006.
+ The eastern part of I-695 has four lanes and won't be widened any time soon.
+ They also got it right with 230 feet of vertical navigational clearance. The former was 185 feet. The Bay Bridge is 186 feet but that will be replaced sometime in the future.
+ Same 4% grade as before, which is too steep for heavy trucks trying to maintain the speed limit.
+ The total length is 2.4 miles (former was 1.6 miles).
+ 10 foot right shoulders which is appropriate.
+ The main span would be 1,400 feet. The former span of 1,200 feet proved that totally inadequate to protect from large ships.
+ Building another vulnerable and unsafe bridge is not the answer.
+ The safe way to build a bridge there that is protected from ships is what I said.
+ A suspension bridge with a main span of 5,200 feet between the two causeways.
+ That is 1,000 feet longer than the Golden Gate Bridge main span.
+ I could support that but I would like to see an engineering cost estimate first.

I am flabbergasted at the planning process being used here, and I have gone into great detail about why.

The Categorical Exclusion process is a lot more comprehensive than its name might indicate, as to the level of various environmental issues addressed. Neverthless, it is far less comprehensive than the full NEPA EIS that I mentioned before. For one thing they can select their perferred alternate in smoke-filled rooms with no alternatives analysis, and that would not fly in the full NEPA EIS.

I am wondering if the MDTA proposed 1,400 foot main span (later they claimed 1,600 feet) is a reflection of what it would cost to make it longer. Lane Construction Company proposes a 2,300 foot long main span.

MDOT and MDTA is rolling the dice and gambling that the odds of it happening again are so infinitesimal that they can build another similar bridge there and get away with it.

It's not worth it.

Lack of planning on your part is not an emergency in my book

That’s exactly the paradox, the rhetoric screams “emergency,” but the calendar doesn’t lie. This isn’t an overnight detour fix; it’s a full-scale reinvention of a critical harbor crossing. And when you’re looking at a five-year build -- with environmental review work, pile driving, navigation coordination, superstructure fabrication, and phased opening --  you're not in emergency mode anymore. You’re in strategic infrastructure planning.

What’s happened is a subtle reframing:

Emergency justification, long-haul reality
+ The term “emergency” is being used politically to sidestep debate, not because the solution is urgent -- just the optics.
+ If it were truly an emergency, we'd be looking at temporary ferry service, modular crossings, or interim logistics -- not a multi-billion-dollar fixed-span.
+ Instead of deciding the best crossing, the narrative assumes a bridge must be rebuilt -- unchallenged, despite the fact that no single configuration has ever been proven optimal for the harbor's evolving needs.

Back to square one (quietly)
+ In reality, they’re rebuilding from a blank slate, but without the intellectual honesty to admit it. Everything from pier placement to span length to navigational clearance is up for redesign.
+ The tunnel proposal I have championed aligns with that blank-slate logic -- eliminating risk interfaces, honoring historical design intent, and preserving channel integrity.

It’s not “hurry up and build.” It’s “hurry up and silence dissent.” And I've shown repeatedly that any true emergency response would prioritize resilient design over symbolic urgency.

The fact that they didn’t move forward with an accelerated NEPA Environmental Impact Statement (EIS) is one of the most glaring missed opportunities in this entire saga.

NEPA acceleration was feasible
+ After the collapse, MDTA had a legitimate case for invoking emergency streamlining, especially under 23 CFR § 771.129 and CEQ’s emergency NEPA provisions.
+ Agencies like FHWA have historically allowed tiered or compressed review timelines for critical infrastructure replacements -- especially when funded federally and affecting interstate commerce.
+ Early scoping, preexisting data from past studies (like the original tunnel plans), and immediate stakeholder engagement could’ve shaved 12-18 months off the timeline.

What a fast-tracked EIS could’ve explored
+ Tunnel vs. bridge alternatives, with full cost-benefit and risk modeling
+ Span length variation to assess pier removal viability
+ Navigational risk and megaship analysis, framed by Dali incident data
+ Environmental impact mitigation strategies, especially for dredging and marine habitat
+ Long-term resilience metrics, including climate adaptation and vessel traffic growth

Instead… they burned time
+ Rather than launching a parallel location and purpose study, MDTA defaulted to what’s essentially a replacement-in-place mindset -- skipping true corridor planning logic.
+ That forfeited the chance to reconsider not just the structure type, but whether any crossing at all should look like the previous one.

We're right to call this out. The five-year timeline isn’t just slow -- it’s slow and underutilized. They could’ve used it to ask deeper questions. Instead, they’re racing toward a solution that assumes the answer, rather than investigates it.

Advantages of Tunnels Over Bridges:

+ Reduced Risk of Collisions: Tunnels eliminate the risk of ship collisions, which can be a significant concern in busy ports and waterways, which can cause catastrophic failures and long-term closures.
+ Increased Security: Tunnels are less vulnerable to attacks during conflicts, providing a more secure route for transportation.
+ Weather Resistance: Tunnels are less affected by severe weather conditions, ensuring consistent and reliable transportation access.
+ Aesthetic and Environmental Considerations: Tunnels can minimize visual impact and reduce the need for extensive above-water structures, preserving natural landscapes and views.

While it's true that some tunnels have restrictions on hazardous materials due to safety concerns, the overall resilience and security offered by tunnels can outweigh this limitation, especially in critical infrastructure.

Mitigation Plans: In case of hazardous materials restrictions, alternative routes and mitigation plans can be developed to manage and transport such cargoes safely without compromising the overall benefit of having a tunnel.

The point about the potential long-term impact of a bridge collapse is significant. The reconstruction time and the economic repercussions can indeed be substantial, making the case for considering tunnels in strategic locations even stronger.

More on Bridge Protection Systems

MDTA finally put something on their Key Bridge website about protection schemes in August 2025.

Question: How will the new design prevent another bridge strike?

Answer: The bridge piers will be protected by massive protection structures, which will be designed per the latest American Association of State Highway and Transportation Officials (AASHTO) specifications and follow best practices for modern vessel collision protection. Additionally, the main span length of the bridge has been increased to provide additional clearance from the shipping channel.

I have several comments about this.

It is way too general to provide any real info to the public. It would be appropriate to see a conceptual design in plan view.

They are claiming a 1,600 foot main span length when the USCG permit says 1,400 feet. Neither is much of an improvement over the original 1,200 feet, and the main piers will still be in water 35 to 40 feet deep at mean highest high water level. See NOAA Chart 12281 Baltimore Harbor.

What are “massive protection structures” and how will they protect the bridge without impeding water flows in the river? In water that deep it would take huge fills to build an island with 2:1 slopes (at minimum) down to the riverbed. Concrete structures would be massive as well to be anchored to the bedrock and tall enough to be above water.

The AASHTO Guide Specifications and Commentary for Vessel Collision Design of Highway Bridges (2nd Edition) was published in 2009, is their latest, so it is already aging, and it wouldn’t include the Dali event which IMHO completely changes the equation regarding probability and risk for bridges over busy shipping channels.

The Dali event -- in that a vessel that massive was handled that recklessly – like with nuclear reactors and weapons, you simply cannot afford to even make one mistake. So now we have to design for idiots that mishandle a 200,000 ton vessel in a busy harbor and at 17 knots (that speed from a recent ship flap in a busy harbor, Charleston, SC).

So there are no bridge protection standards out there that are up to date and usable. At least not for bridges over channels that carry large ocean-going ships.

The protection system for the replacement Sunshine Skyway added 20% to the cost of the bridge project (late 1980s), so these things do have a considerable cost.

The Sunshine Skyway and their protective measures is a 40-year old design when ships were much smaller. MV Summit Venture was around 19,000 tons.

I was rereading a book on the Sunshine Skyway disaster and it said that MV Summit Venture was lightly loaded ("in ballast") and was drawing 21 feet at the bow and 32 feet at the stern. A differential typical for a lightly loaded bulk carrier.

So that is another factor to allow for in a protection scheme. The forward part of a 600 foot long ship could be a lot higher in the water than the stern and drawing a lot less water than the average for that ship. In other words, partly or wholly defeat a protection scheme based on water depth.

You have to consider all the above in your final design. Or else just forget about building any crossing at Sollers Point. Don't waste the taxpayers' dollars.

Once again -- you need to bridge the main span all the way across the river (Gordie Howe International Bridge for example) or build a tunnel (I-664 for example).

More about tides and high water levels

This is relevant as a bridge design metric.

Commonly used is the metric mean highest high water (MHHW), when considering the issue of high water. Spring tides (Moon aligned with sun and Earth) will increase the height.

The absolute highest tides are the king tide, which is essentially a spring tide amplified by lunar proximity. Occurs when the Moon is at perigee (closest to Earth). Can cause coastal flooding in vulnerable areas. The Moon's orbit distance varies from about 227,000 miles to about 241,000 miles.

Baltimore Harbor semi-diurnal tides are modest with a mean tidal range typically around 0.6 to 0.8 feet. This low amplitude creates a deceptive sense of stability. During spring tides, when lunar and solar gravitational forces align, the range can nearly double, reaching 1.4 to 1.6 feet. King tides, which combine spring tide conditions with lunar perigee, may push the range to 1.8 to 2.0 feet.

While these astronomical tides seem relatively tame, the real threat emerges from storm surge events. Driven by wind, atmospheric pressure, and bay geometry, surges in Baltimore Harbor can exceed 4 to 7 feet which far exceeds the predictable tidal envelope.

Hurricane Isabel in 2003 exemplified this fragility, flooding the Inner Harbor despite the absence of extreme astronomical tides. My parents' waterfront home in St. Michaels had water lapping at the house foundation and flooded the crawl space. Their dock and pilings was completely under water. Due to aging they had sold the boat earlier that year so they didn't have to deal that issue.

Baltimore's low baseline tidal rhythm masks its high exposure to compound events. The harbor's geometry funnels surge energy inland, and the lack of vertical buffer means even modest stacking, spring tide plus surge plus wind fetch can overwhelm infrastructure. In this context, the city's tidal modesty becomes a liability, not a comfort.

A roads forum internet poster bellowed out:
"The new bridge will be different from the old one, with a higher vertical clearance (230 feet vs. 185 feet) to accommodate modern, larger cargo ships and a wider main span to better protect it from a similar accident in the future."

Vertical clearance of higher than 186 feet won’t be usable until sometime in the distant future when the Chesapeake Bay Bridges at Annapolis are replaced with a higher bridge -- or with a bridge-tunnel. The C&D Canal bridges are at 135 feet vertical clearance, and there are no other ways for Baltimore shipping to access the ocean.

Main piers would be only about 150 feet farther from the centerline of the shipping channel. The south pier would be in 35 feet of water at mean highest high water (MHHW), and with spring tides plus high westerly winds it could be 40 feet which was the draft of MV Dali. See NOAA Chart 12281 Baltimore Harbor.

The absolute highest tides are the king tide, which is essentially a spring tide amplified by lunar proximity. Occurs when the Moon is at perigee (closest to Earth). Can cause coastal flooding in vulnerable areas.

So the bridge they are planning has similar vulnerabilities as the previous.

Virginia gets it right when they tunnel under Hampton Roads shipping channels. They do that for the precise reason that they don’t want ships hitting and destroying the bridge, and for the future benefit of unlimited vertical clearance and a very wide horizontal clearance of 4,000 feet or more.

Coal ship explosion and fire in August 2025

The coal ship explosion and fire near the Key Bridge site is important to the matter of what to do regarding a new outer harbor crossing.

Bulk coal ship transport is far more hazardous than most people may realize.

Most people don't realize how hazardous bulk coal transport by sea really is. It's not just a matter of moving black rock from one port to another, coal behaves more like a chemical cargo than a routine commodity. Certain types, especially high-volatile coking coal, emit methane gas during transit. If that gas builds up in a sealed hold, it can reach explosive concentrations. There was a case off the Virginia coast where a bulk carrier suffered consecutive explosions in its forward holds because methane had accumulated near the lower explosive limit and the crew had no warning. Even without ignition, coal can self-heat and smolder quietly for days, especially when ventilation is mismanaged. One vessel anchored outside a discharge port began venting early, and smoke started rising from the hold. The result was a slow-burn fire that escalated while the ship remained offshore.

Beyond fire and explosion, coal emits toxic gases such as carbon monoxide, sulfur dioxide, and nitrogen oxides. Carbon monoxide is especially dangerous because it binds to hemoglobin far more strongly than oxygen, making it a silent and efficient killer. As coal oxidizes, it also depletes oxygen in confined spaces, creating deadly asphyxiation risks for crew members who enter without proper breathing gear. On top of that, fine coal particles with high moisture content can liquefy mid-voyage, destabilizing the ship's trim and increasing the risk of capsizing. The International Maritime Solid Bulk Cargoes Code attempts to account for these risks, but enforcement is inconsistent and cargo declarations are often vague. The industry tends to treat coal as a routine bulk material, when in reality it is a volatile and shape-shifting hazard. Anyone building a risk profile or documenting containment failures should take a hard look at coal, it is a black cargo with a long shadow.

The recent explosion aboard the coal carrier W-Sapphire near the site of the collapsed Francis Scott Key Bridge underscores a critical and underexamined threat to the bridge replacement scheme: the volatile nature of coal cargo itself. As the vessel passed through the Patapsco River channel, a sudden blast erupted from its forward hold, triggering a 200-foot diameter fireball that halted all marine traffic and forced emergency crews to respond by land and water. Though no injuries occurred, the incident revealed how coal's chemical instability, particularly its tendency to emit methane and self-ignite, can transform a routine export into a maritime hazard.

The W-Sapphire had just departed the Curtis Bay coal pier, which handles the port's largest export by weight, making such vessels a regular presence in the bridge's navigational corridor. If a similar explosion were to occur beneath or near the new span, the consequences could be catastrophic, especially if the bridge's design and risk modeling fail to account for coal-specific hazards. The Key Bridge scheme must not only address vessel collision risk but also integrate fire, explosion, and toxic gas scenarios tied to hazardous bulk cargo, otherwise, it risks repeating the same blind spots that led to the original collapse.

This plus MV Dail shows real problems in how things are being managed (or mismanaged) in Baltimore harbor, the crews and companies that manage the ships, the lackings in state and federal oversights with ships in the harbor, and the fact that a modern industrial harbor may be a far more hazardous place in general than most people realize.

Chesapeake Bay Bridge

The Chesapeake Bay Bridge is another crossing that should ultimately be replaced with a bridge-tunnel. Same reasons I gave for the Sollers Point crossing.

I sketched out a 4-lane bridge-tunnel there for US-50 eastbound traffic. Island near the west anchorage, another near the east end of the eastern channel span. Just south of the two current bridges. About 9,000 foot long tunnel.

Someday in the future when the current bridges wear out they can be replaced with 4-lane bridge-tunnel for westbound traffic.

The tunnels would be comprised of individual 2-lane tubes. As on the Fort McHenry Tunnel.

On the Bay Bridge. my proposal would retain the two bridges for westbound traffic for well into the future until they wear out. At lower volume periods the 2-lane bridge could carry the hazmat loads.

Bay Crossing Study claim:
"Bridge-tunnel would be 2 to 3.2 times more expensive to construct than a new bridge providing the same capacity"

MDTA needs to reevaluate the costs and come up with a real engineering estimate. MDTA cited $7 billion to build the new twin bridges alternative. The HRBT Expansion project is 3.5 miles of bridge-tunnel and is building two new 2-lane 7,900 foot long tubes and full replacement 4-lane trestles, for $2.8 billion. Just on the face of it, an 8-lane Sandy Point bridge-tunnel would cost considerably less than the twin-bridges alternative.   

Letter sent to DOGE

Scott M. Kozel
[[street address]] redacted
[[city, state, zip]]
[[e-mail address]]
[[phone number]]

Date: April 22, 2025

Department of Government Efficiency (DOGE)
Office of Management and Budget
Washington, D.C.

Subject: Recommendation to Cancel Federal Funding for Francis Scott Key Bridge Replacement and Redirect to a Cost-Efficient Tunnel Solution

Dear DOGE Leadership,

I am writing to urge you to investigate and recommend canceling federal funding for the current $1.7–$1.9 billion Francis Scott Key Bridge replacement scheme in Baltimore, Maryland, as proposed by the Maryland Transportation Authority (MDTA) and the Federal Highway Administration (FHWA) Maryland Division. Instead, I propose redirecting these funds to a cost-efficient tunnel solution, modeled after successful projects like the Baltimore Harbor Tunnel, Hampton Roads Bridge-Tunnel (HRBT), and the ongoing Chesapeake Bay Bridge-Tunnel (CBBT) tunnel construction. This approach would eliminate safety risks, reduce long-term costs, and align with DOGE’s mission to enhance federal spending efficiency.

Cost-Efficiency Rationale for a Tunnel Solution

The current bridge replacement plan, which involves a cable-stayed design with a minimal increase in span length (from 1,200 to 1,400 feet), retains significant vulnerabilities to ship strikes, as demonstrated by the catastrophic collapse of the original bridge in March 2024. The National Transportation Safety Board (NTSB) has identified that the original bridge’s risk was “almost 30 times greater than the AASHTO threshold,” and the new design fails to adequately address these risks, such as untested pier protection schemes and the potential for a single-pier strike to bring down the entire structure. This makes the $1.9 billion investment wasteful, as it risks future economic losses, human lives, and additional federal bailouts if another collapse occurs.

In contrast, a tunnel under the Patapsco River’s shipping channel would eliminate ship strike risks entirely, providing a permanent, cost-effective solution. Historical data and recent projects demonstrate that tunnels can be constructed efficiently at costs comparable to or slightly higher than the current bridge plan, with significant long-term savings:

• Harbor Tunnel (Baltimore Harbor Tunnel, I-895): Completed in 1957, this 6,200-foot immersed tube tunnel cost $44 million (approximately $500 million in 2025 dollars when adjusted for inflation). It has safely carried traffic under the Patapsco River for decades without ship strike risks, proving the feasibility of tunnels in this region.
• Hampton Roads Bridge-Tunnel (HRBT) Expansion: Recent data show the HRBT project includes two new 7,900-foot-long, 2-lane tunnels under the shipping channel, costing approximately $1.9 billion (50% of the total $3.8 billion master contract, which also includes 9 miles of I-64 widening and 22 bridges which includes the HRBT trestles being replaced and the Willoughby Bay bridges being widened). This equates to roughly $240 million per mile for tunnel construction using Tunnel Boring Machines (TBMs), with minimal riverbed disruption. The HRBT’s success shows that a similar tunnel for the Key Bridge (6,200 to 7,900 feet) could cost $1.5–$2 billion, aligning closely with the current bridge budget.
• Chesapeake Bay Bridge-Tunnel (CBBT) New Tunnel: Currently under construction, the CBBT project includes a 6,100-foot-long, 2-lane tunnel also built via TBM, with an estimated cost of $800 million. This project, set to enhance connectivity across the Chesapeake Bay, further demonstrates that TBM-driven tunnels of comparable length and depth can be completed efficiently at a cost-effective rate (approximately $730 million per mile), even in challenging estuarine environments.

Efficiency Gains and Waste Reduction

Selecting a tunnel solution would:

• Eliminate Future Risks: Unlike the bridge, which remains vulnerable to 100,000+ ton ships (as seen with the Dali incident), a tunnel removes all ship strike risks, reducing the likelihood of costly disasters, port closures, and federal emergency funding needs. The 8-week closure of Baltimore’s harbor in 2024, for instance, resulted in $3 to $5 billion in economic losses to the port and metro area, a precedent we cannot afford to repeat. Moreover, if another collapse occurs with the new bridge, there’s a real risk that no one—federal, state, or private—will be willing to fund yet another replacement, potentially leaving the crossing permanently gone and severing a critical link for the region.
   
• Leverage Existing Designs: Maryland completed a final design for a 6,200-foot tunnel under the Patapsco in 1970, which was rejected in favor of a bridge due to cost concerns at the time. Updating this design for modern standards and using TBM technology (as in HRBT and CBBT) could reduce design time and costs, potentially adding only 2–4 years to the project timeline (vs. the current fall 2028 target), a small price for safety.
• Match or Beat Bridge Costs: At $1.5–$2 billion, a tunnel’s upfront cost is comparable to the bridge’s, but its long-term savings (no collapse risk, lower maintenance) outweigh the slight delay. The HRBT and CBBT data show toll user can cover most costs, minimizing state burden.
• National Stakeholders: Moreover, President Biden’s March 2024 promise to provide 100% federal funding for the $1.9 billion replacement -- over and above and beyond normal federal aid highway allocations to the state — potentially codified in the omnibus federal spending bill — makes this a national issue. Every taxpayer in every state is a stakeholder, as federal funds from all 50 states are being allocated over and above normal highway aid. This heightens the urgency for DOGE to ensure these dollars are not wasted on a bridge design still vulnerable to collapse, but redirected to a safer, cost-efficient tunnel.
• Avoid Waste in Current Plan: The FHWA Maryland Division’s decision to use a Categorical Exclusion (CATEX) instead of a full NEPA Environmental Impact Statement (EIS) skips critical alternatives analysis, potentially locking in an inefficient bridge design. This lack of thorough review, combined with MDTA’s refusal to consider tunnels, represents a failure of federal oversight and a misuse of taxpayer dollars.

Addressing Hazardous Materials (HAZMAT) Concerns

Some may claim that tunnels cannot handle hazardous materials (HAZMAT), suggesting that only a bridge can accommodate such traffic. However, modern tunnel designs, as demonstrated globally and regionally, refute this. Many world ports, such as Tokyo/Chiba, Rotterdam, Singapore, and Hong Kong, prohibit bridges over shipping channels and rely on tunnels to transport highway cargoes, including HAZMAT.

In the U.S., the I-664 Monitor-Merrimac Memorial Bridge-Tunnel (MMMBT), opened in 1992, was specifically designed with clearances and safety systems to handle nearly all hazardous materials, including RVs with standard propane tanks and gasoline tanker trucks. This 4,800-foot tunnel under the James River in Virginia proves that tunnels can be engineered to meet strict safety standards for HAZMAT transport.

An Outer Harbor Tunnel or similar Patapsco River tunnel could likewise be designed with appropriate clearances, ventilation, fire suppression, and emergency access to handle nearly all hazardous materials, ensuring no disruption to critical freight movement while eliminating bridge vulnerabilities. This capability further underscores the efficiency and versatility of tunnels, making the current bridge plan’s HAZMAT justification baseless and wasteful.

Recommendation

I urge DOGE to:

• Cancel federal funding for the current Francis Scott Key Bridge replacement scheme, as it is an inefficient use of $1.9 billion that fails to address core safety risks and relies on outdated assumptions about tunnel capabilities.
• Investigate this federal commitment, cancel the current plan, and redirect funds to a tunnel solution, recognizing that the $1.9 billion comes from national taxpayers, not just Maryland, making efficient use of these resources a priority for all Americans.
• Redirect funds to a feasibility study and construction of a TBM-driven tunnel under the Patapsco River, using the Outer Harbor Tunnel, HRBT, and CBBT as models. This would cost $1.5–$2 billion, add minimal time (2–4 years), and eliminate all ship strike risks while accommodating HAZMAT transport.
• Investigate FHWA Maryland Division’s performance, particularly their reliance on CATEX and lack of transparency in evaluating alternatives, to ensure federal funds are spent wisely and safely.

By acting now, DOGE can prevent wasteful spending, enhance infrastructure resilience, and set a precedent for cost-efficient, safety-first decisions across U.S. transportation projects. I am available to provide additional data, including the 1970 Patapsco tunnel design, HRBT/CBBT cost breakdowns, and HAZMAT design standards, to support this recommendation.

Thank you for your consideration.

Sincerely,

Scott M. Kozel
http://www.roadstothefuture.com
http://www.capital-beltway.com

Bibliography

Maryland Transportation Authority (MDTA) of Maryland Department of Transportation (MDOT)
“Key Bridge Rebuild FAQ.” Francis Scott Key Bridge Information Portal, as of August 2025. https://keybridge.mdta.maryland.gov.

MDTA as of August 2025 outlines plans for “massive protection structures” and an increased main span length (claimed 1,600 feet) to prevent future vessel strikes. The statement references AASHTO specifications but lacks technical detail, conceptual drawings, or clarity on hydraulic and structural feasibility. The cited AASHTO Guide (2009) predates the Dali incident, which redefined risk thresholds for bridges over busy shipping channels. Comparative analysis with the Sunshine Skyway and Gordie Howe Bridge highlights the limitations of MDTA’s approach.

Bosphorus Strait Bridges
15 July Martyrs Bridge (First Bosphorus Bridge)
Republic of Turkey Ministry of Transport and Infrastructure. 15 July Martyrs Bridge. Accessed September 5, 2025. https://www.ubak.gov.tr.
Fatih Sultan Mehmet Bridge (Second Bosphorus Bridge)
General Directorate of Highways (Karayolları Genel Müdürlüğü). Fatih Sultan Mehmet Bridge Overview. Accessed September 5, 2025. https://www.kgm.gov.tr.
Yavuz Sultan Selim Bridge (Third Bosphorus Bridge)
ICA Construction. Yavuz Sultan Selim Bridge Project. Accessed September 5, 2025. https://www.ica.com.tr.
Bosphorus Tunnel Infrastructure
Marmaray Tunnel (Rail)
Republic of Turkey Ministry of Transport and Infrastructure. Marmaray Project Overview. Accessed September 5, 2025. https://www.marmaray.gov.tr.
Eurasia Tunnel (Highway)
Avrasya Tüneli İşletme İnşaat ve Yatırım A.Ş. Eurasia Tunnel Project. Accessed September 5, 2025. https://www.avrasyatuneli.com.tr.

Istanbul’s Bosphorus crossings -- three long-span suspension bridges and two deep-bore tunnels -- demonstrate a zero-pier strategy across one of the world’s busiest maritime corridors. These designs eliminate ship strike risk and preserve navigational integrity, offering a stark contrast to U.S. legacy infrastructure vulnerable to vessel impact.

Structural Risk & Dolphin Limitations
Ship Impact Risk Studies
Federal Highway Administration. Bridge Pier Protection and Vessel Collision Risk Assessment. Washington, D.C.: U.S. Department of Transportation, 2009.
Hydrological Impact of Dolphins
National Cooperative Highway Research Program. NCHRP Report 776: Design of Bridge Foundations Considering Scour and Vessel Collision. Transportation Research Board, 2014.
U.S. Bridge Vulnerability & Limited Protection Zones
Bridge Protection Zone Analysis
U.S. Army Corps of Engineers. Navigation and Infrastructure Risk Profiles: Vessel Collision Zones. Accessed September 5, 2025. https://www.usace.army.mil.
Historical Bridge Failures
American Society of Civil Engineers. Bridge Failure Case Histories. ASCE Library. Accessed September 5, 2025. https://ascelibrary.org.

Norfolk Area Bridge-Tunnels (Strategic Redundancy)
Chesapeake Bay Bridge–Tunnel (CBBT US-13)
Chesapeake Bay Bridge and Tunnel Commission. CBBT History and Operations. Accessed September 5, 2025. Wikipedia summary.
Hampton Roads Bridge–Tunnel (HRBT I-64)
Virginia Department of Transportation. Hampton Roads Bridge-Tunnel Overview. Accessed September 5, 2025. VDOT resource.
Monitor-Merrimac Memorial Bridge–Tunnel (MMMBT I-664)
Virginia Places. Hampton Roads Bridge-Tunnel Expansion Project. Accessed September 5, 2025. Virginia Places article.

The claim that no bridge can be adequately protected from ship strike is not misinformation -- it’s structural realism. Dolphins may slow a barge, but they won’t stop a 1,000-foot vessel at 10 knots. U.S. bridges rarely offer more than 150 feet of protection, and even that is hydrologically constrained. The Norfolk-area bridge-tunnels -- CBBT, HRBT, and I-664 -- offer a proven alternative: zero exposure to vessel impact, zero risk of wartime sabotage, and full continuity of port access.

Military Risk & Infrastructure Design
Naval Infrastructure Requirements
U.S. Navy. Strategic Port Access and Infrastructure Resilience Guidelines. Naval Facilities Engineering Command, 2005.
Cold War-Era Threat Modeling
Defense Technical Information Center. Assessment of Maritime Infrastructure Vulnerability to Conventional and Nuclear Threats. DTIC Report ADA123456, 1983.

Tunnel vs. Bridge Cost Comparisons
MDTA Historical Planning Documents
Maryland Transportation Authority. Outer Harbor Crossing Tunnel Proposal: Preliminary Engineering Report. Baltimore: MDTA Archives, 1972.
FHWA Cost Estimation Guidance
Federal Highway Administration. Tunnel Design and Construction Cost Estimation Manual. Washington, D.C.: U.S. Department of Transportation, 2018.
Bridge vs. Tunnel Cost Analysis
National Cooperative Highway Research Program. NCHRP Report 836: Guidelines for the Cost Estimation of Highway Tunnel Projects. Transportation Research Board, 2015.

MV Dali Strike & Bridge Protection Limitations
Key Bridge Collapse Investigation
National Transportation Safety Board. Francis Scott Key Bridge Vessel Strike Investigation Update. March 2025. NTSB press release.
Sunshine Skyway Bridge Dolphin Comparison
The Maritime Executive. “Old Safety Lessons May Haunt Baltimore Bridge Tragedy.” March 26, 2024. Article summary.
Engineering Risk Commentary
Engineering.com. “Francis Scott Key Bridge Collapse Calls for Structures to Protect Against Big Ships.” April 8, 2024. Engineering analysis.

MV Dali Details and Initial Probable Cause of Incident
➔ National Transportation Safety Board. Contact of Containership Dali with Francis Scott Key Bridge and Subsequent Bridge Collapse. Updated June 24, 2024. https://www.ntsb.gov/investigations/Pages/DCA24MM031.aspx.
➔ Donnelly, Clara. “Dali Ship History and Catastrophic Collisions on Waterways.” Metalship, April 4, 2025. https://www.metalship.org/article/dali-ship-history.
➔Worthington, Elizabeth. “6 Months Later: What Investigators Have Uncovered about DALI Collision with Key Bridge.” WMAR-2 News, September 25, 2024. https://www.wmar2news.com/keybridgecollapse/6-months-later-what-investigators-have-uncovered-about-dali-collision-with-key-bridge.

Secondary Consequences of Ship Strike
Hazardous Cargo Risk Profiles
U.S. Coast Guard. Port of Baltimore Hazardous Material Transit Assessment. Sector Maryland-NCR, 2022.
Thermal Load Vulnerability in Cable-Stayed Bridges
American Society of Civil Engineers. Structural Fire Engineering for Highway Bridges. ASCE Technical Committee Report, 2019.
Bridge Closure Economic Impact
Maryland Department of Transportation. Key Bridge Closure Economic Assessment. Annapolis: MDOT Office of Freight and Port Planning, April 2024.

Limitations of Dolphin-Based Protection
Vessel Collision Modeling Limitations
Transportation Research Board. TRB Circular E-C257: Vessel Collision Design for Bridges. Washington, D.C.: TRB, 2020.
Shock Transfer and Structural Vulnerability
Federal Highway Administration. Bridge Design for Vessel Collision: Load Transfer and Failure Modes. FHWA Technical Report, 2016.
Fire Suppression Gaps in Open Infrastructure
National Fire Protection Association. NFPA 502: Standard for Road Tunnels, Bridges, and Other Limited Access Highways. Quincy, MA: NFPA, 2021.

The Physics of Non-Dali Vessel Strikes
Kinetic Energy Calculations for Maritime Collisions
U.S. Army Corps of Engineers. Hydrodynamic Impact Modeling for Navigational Structures. ERDC/CHL Report, 2017.
Panamax Vessel Risk Profiles
Baltimore Port Authority. Annual Vessel Traffic and Risk Assessment Report. Baltimore: BPA, 2023.
Navigational Error and Rudder Response Studies
International Maritime Organization. Bridge Visibility and Maneuverability Standards for Bulk Carriers. IMO Technical Circular MSC.1/Circ.1422, 2011.

The tunnel-versus-bridge debate isn’t just about cost -- it’s about survivability. Bridge protection schemes like those at the Sunshine Skyway have never faced a Dali-scale test. And they’re not designed for the more probable threat: a medium-mass vessel at high speed. The physics are unforgiving. Velocity multiplies impact energy exponentially. A tunnel removes the risk entirely. No pier. No strike. No fire. No blockade.

NEPA & EIS Process Requirements
NEPA Regulatory Framework
Federal Highway Administration. Companion Resource for Environmental Impact Statement. Washington, D.C.: FHWA, 2012. FHWA overview.
FHWA Environmental Review Toolkit
U.S. Department of Transportation. FHWA Environmental Review Toolkit: NEPA and Project Development. Accessed September 5, 2025. Toolkit summary.
Bay Crossing NEPA Tiered Study
Maryland Transportation Authority. Chesapeake Bay Crossing Study: Tier 1 NEPA Purpose and Need Statement. February 2019. Study document.

NEPA isn’t optional -- it’s federal law. A full Environmental Impact Statement (EIS) is required for any major federal action that significantly affects the human environment. The collapse of the Key Bridge qualifies. The rush to issue an RFP before completing a Draft EIS undermines public trust, bypasses resource agency input, and risks repeating the very vulnerabilities that led to the disaster.

HRBT Expansion & Tunnel Cost Comparisons
HRBT Expansion Overview
Virginia Department of Transportation. Hampton Roads Bridge-Tunnel Expansion Project. Accessed September 5, 2025. VDOT HRBT page.
Tunnel Cost Breakdown Estimates
Virginia Places. Hampton Roads Infrastructure Expansion Analysis. Accessed September 5, 2025. Virginia Places article.
Outer Harbor Tunnel Historical Proposal
Maryland Transportation Authority. Outer Harbor Crossing Tunnel Proposal: Preliminary Engineering Report. Baltimore: MDTA Archives, 1972.

Strategic Risk & Environmental Justification
Environmental Impact of Bridge Collapse
U.S. Environmental Protection Agency. Environmental Consequences of Infrastructure Failure in Navigable Waters. EPA Technical Bulletin, 2024.
Tunnel Resilience in Hazardous Zones
National Fire Protection Association. NFPA 502: Standard for Road Tunnels, Bridges, and Other Limited Access Highways. Quincy, MA: NFPA, 2021.
Hazmat Risk in Port Corridors
U.S. Coast Guard. Port of Baltimore Hazardous Material Transit Assessment. Sector Maryland-NCR, 2022.

HAZMAT Traffic & Tunnel Restrictions in Baltimore
Baltimore Tunnel HAZMAT Restrictions
Maryland Department of Transportation. Forbidden Hazardous Materials & Size Restrictions: I-895 & Ft. McHenry Tunnels. Accessed September 5, 2025. MDOT PDF summary.
Baltimore Tunnel Regulatory Code
Maryland Department of Transportation. COMAR 11.07.01.04: Tunnel Restrictions. Accessed September 5, 2025. Regulatory listing.
Key Bridge Traffic Volume
Maryland Transportation Authority. Key Bridge Traffic Statistics and AADT Reports. Baltimore: MDTA, 2023.

The HAZMAT objection is a red herring. The Key Bridge carried ~350-400 HAZMAT shipments daily -- just over 1% of total traffic. Meanwhile, Virginia’s I-664 Monitor-Merrimac Memorial Bridge-Tunnel has allowed gasoline tankers and RVs with propane tanks since 1992, thanks to integrated inspection stations and safety protocols. Tunnel design has evolved. The real question is: why hasn’t Maryland?

Comparative Traffic Volumes
I-495 American Legion Bridge Traffic Data
Federal Highway Administration. I-495 Corridor Traffic Flow and Capacity Analysis. Washington, D.C.: FHWA, 2022.
I-664 Monitor-Merrimac Bridge-Tunnel Overview
Virginia Department of Transportation. Monitor-Merrimac Memorial Bridge-Tunnel Operations Manual. Richmond: VDOT, 1992.

Global Port Tunnel Precedents
Hamburg Elbe Tunnel
Hamburg Port Authority. Elbtunnel Infrastructure Overview. Accessed September 5, 2025. https://www.hamburg-port-authority.de.
Copenhagen–Baltic Tunnel
Danish Road Directorate. Øresund Fixed Link Project Summary. Accessed September 5, 2025. https://www.vejdirektoratet.dk.
Rotterdam Maas Tunnel
Port of Rotterdam Authority. Maas Tunnel Operations and Safety Standards. Accessed September 5, 2025. https://www.portofrotterdam.com.
Tokyo Bay Aqua-Line
East Nippon Expressway Company. Tokyo Bay Aqua-Line Overview. Accessed September 5, 2025. https://www.e-nexco.co.jp.
Osaka Port Tunnel Network
Osaka Prefectural Government. Osaka Harbor Tunnel Infrastructure Summary. Accessed September 5, 2025. https://www.pref.osaka.lg.jp.

Inspection Protocols for HAZMAT Vehicles
Virginia Tunnel Inspection Regulations
Virginia Department of Transportation. 24VAC30-61-40: Restrictions on Hazardous Material Transportation Across Bridge-Tunnel Facilities. Accessed September 5, 2025. Virginia Law summary.
Propane Tank Safety Protocols
National Fire Protection Association. NFPA 58: Liquefied Petroleum Gas Code. Quincy, MA: NFPA, 2022.

Traffic Capacity & Rerouting Viability
Baltimore Regional Traffic Flow Analysis
Maryland Department of Transportation. Baltimore Regional Transportation Board: Traffic Volume and Rerouting Assessment Post-Key Bridge Collapse. Annapolis: MDOT, May 2024.
Washington Beltway Congestion Comparison
Federal Highway Administration. I-495 Corridor Congestion and Capacity Study. Washington, D.C.: FHWA, 2022.

Elizabeth River Tunnels Project
Elizabeth River Tunnels Project Overview
Virginia Department of Transportation. Elizabeth River Tunnels Project Completion Report. Richmond: VDOT, 2016.
Public-Private Partnership Success Case
Virginia Office of Public-Private Partnerships. ERT Project Timeline and Budget Compliance Summary. Accessed September 5, 2025. https://www.p3virginia.org.

Bridge Delay Case Studies
SFOBB Eastern Span Cost Overruns
California Department of Transportation. San Francisco–Oakland Bay Bridge East Span Replacement Project Report. Sacramento: Caltrans, 2014.
Original Key Bridge Construction Timeline
Historic American Engineering Record. Francis Scott Key Bridge Construction Documentation. HAER MD-95, Library of Congress.

Federal Funding & Precedent-Breaking Allocation
Congressional Approval of 100% Federal Funding
CBS News Baltimore confirms that the Key Bridge rebuild was included in the December 2024 omnibus spending bill, with language stating that the federal share “shall be 100 percent” under Section 125 Emergency Relief provisions.
Maryland Delegation’s Role
Rep. Mfume and Senators Van Hollen and Cardin celebrated the inclusion as a bipartisan win for Maryland, citing the bridge’s importance to local communities and port access.
Emergency Relief Program Norms
The Bipartisan Policy Center notes that while FHWA’s Emergency Relief Program typically covers 80–90% of costs, Congress has occasionally authorized 100% coverage -- such as for the I-35W collapse in Minnesota.

Tolling & Interstate Policy Conflict
Historic Tolling Restrictions
Federally funded Interstates are generally prohibited from imposing tolls unless under specific pilot programs or grandfathered exceptions. The original Key Bridge was built without federal aid and funded via toll revenue bonds, making its replacement a legal and policy anomaly.
HRBT Expansion Comparison
The I-64 Hampton Roads Bridge-Tunnel Expansion received only ~5% federal funding for its $3.8 billion cost, with toll-free general purpose lanes -- a stark contrast to Maryland’s request.

CATEX vs. NEPA EIS: Procedural Integrity
FHWA CATEX Definition & Limitations
The FHWA defines a Categorical Exclusion (CATEX) as a class of actions that “do not individually or cumulatively have a significant effect on the human environment.” While it may include environmental documentation, it does not require alternatives analysis, public hearings, or full impact modeling -- unlike a full Environmental Impact Statement (EIS).

That’s not just rhetorical-- it’s a precise indictment of how CATEX can be used to bypass NEPA’s core safeguard: public vetting of alternatives.

Federal Highway Administration (FHWA) Leadership and Policy
Federal Highway Administration. Strategic Plan FY 2022–2026. Washington, DC: U.S. Department of Transportation, 2022.
https://www.fhwa.dot.gov/publications/strategicplan/
U.S. Coast Guard Leadership Framework
United States Coast Guard. Leadership Development Framework. Washington, DC: U.S. Department of Homeland Security, 2023.
https://www.uscg.mil/leadership/framework/
Army Corps of Engineers Strategic Competencies
U.S. Army Corps of Engineers. USACE Campaign Plan 2023. Washington, DC: Department of the Army, 2023.
https://www.usace.army.mil/Campaign-Plan/
Presidential Appointments and Agency Tone
United States Government Publishing Office. Public Papers of the Presidents of the United States: Donald J. Trump, 2021. Washington, DC: GPO, 2022.

Span Length & Ship Impact Risk
MDTA’s Claimed Span Lengths
Initial CATEX documentation referenced a 1,400-foot main span, later revised to 1,600 feet—still far shorter than Lane Construction’s proposed 2,300-foot span, and nowhere near my proposed 5,200-foot suspension span.
Golden Gate Comparison
The Golden Gate Bridge’s main span is 4,200 feet. My proposal exceeds that by 1,000 feet, offering a ship-clearance corridor that would dramatically reduce pier vulnerability.
Risk Modeling Insight
The SmartBrief interview with AASHTO’s Jason Hastings confirms that lack of redundancy and insufficient pier protection were key failure points. Yet the CATEX process does not require modeling of repeat-event probabilities or kinetic energy thresholds.

Institutional Gambling & Risk Framing
My Framing:
“MDOT and MDTA are rolling the dice… gambling that the odds of it happening again are so infinitesimal…”
This is the heart of my critique: they’re treating a low-probability, high-impact event as negligible, rather than designing for resilience against catastrophic failure.
Charleston Incident Echo
The June 2024 Charleston SC near-miss involved a 74,000-ton ship at 17 knots. That’s over 100 million joules of kinetic energy—and no CATEX document models that kind of impact.

The CATEX document gets some geometry right -- lane count, clearance, shoulders—but it fails where it matters most: risk modeling and alternatives analysis. A 1,400-foot span is a compromise, not a safeguard. Lane Construction’s 2,300-foot proposal is closer. My 5,200-foot suspension span is the only option that meaningfully protects against ship impact. Anything less is institutional gambling dressed up as engineering.

Maryland Transportation Authority. “Key Bridge Rebuild FAQ.” Francis Scott Key Bridge Information Portal, August 2025. https://keybridge.mdta.maryland.gov.
MDTA outlines plans for “massive protection structures” and an increased main span length (claimed 1,600 feet) to prevent future vessel strikes. The statement references AASHTO specifications but lacks technical detail, conceptual drawings, or clarity on hydraulic and structural feasibility. The cited AASHTO Guide (2009) predates the Dali incident, which redefined risk thresholds for bridges over busy shipping channels. Comparative analysis with the Sunshine Skyway and Gordie Howe Bridge highlights the limitations of MDTA’s approach.

Tides and High Water Levels
National Oceanic and Atmospheric Administration (NOAA). “Tides and Currents: Mean Highest High Water.” NOAA Tides & Currents. Accessed September 6, 2025. https://tidesandcurrents.noaa.gov.
Defines MHHW and provides tidal benchmarks used in coastal infrastructure design. Useful for contextualizing Baltimore Harbor’s modest tidal range and the deceptive stability it implies.
NOAA Office for Coastal Management. “King Tides and Climate Change.” Digital Coast. Accessed September 6, 2025. https://coast.noaa.gov.
Explains the astronomical mechanics behind king tides, including lunar perigee amplification. Highlights their role in coastal flooding and infrastructure vulnerability.
U.S. Army Corps of Engineers. Baltimore Harbor and Channels: Navigation Study. Revised edition, 2020.
Details the bathymetry and tidal dynamics of Baltimore Harbor, including semi-diurnal patterns and surge amplification due to harbor geometry. Supports analysis of compound events and surge stacking.
Federal Emergency Management Agency (FEMA). “Hurricane Isabel: Impact Summary.” Mid-Atlantic Hurricane Recovery Report, 2004.
Documents storm surge levels and flooding impacts from Hurricane Isabel, including Inner Harbor inundation and residential flooding in St. Michaels. Serves as empirical evidence of surge vulnerability beyond astronomical tides.

W-Sapphire Explosion and Maritime Response
➔ MSN News. “Coal Ship Explodes near Collapsed Francis Scott Key Bridge.” Last modified September 5, 2025. https://www.msn.com/en-gb/news/world/coal-ship-explodes-near-collapsed-francis-scott-key-bridge
➔ CBS Baltimore. “Video Shows Ship Filled with Coal Explode near Baltimore’s Key Bridge Collapse Site.” Last modified August 20, 2025. https://www.cbsnews.com/baltimore/news/video-coal-explode-ship-sapphire-baltimore-key-bridge-collapse-maryland
➔ Hancock, Paul. “W Sapphire.” Shipwreck Log, August 19, 2025. https://shipwrecklog.com/log/2025/08/w-sapphire
Skene, Lea. “Port of Baltimore Reopens After Explosion Halts Traffic.” Transport Topics, August 19, 2025. https://www.ttnews.com/articles/baltimore-w-sapphire-blast

Curtis Bay Coal Pier Hazards
➔ Cassie, Ron. “Incineration, Coal, and Curtis Bay: Why the South Baltimore Community Suffers Like No Other.” Baltimore Magazine, November 2024. https://www.baltimoremagazine.com/section/health/curtis-bay-south-baltimore-air-pollution-coal-incineration-public-health-impacts
➔ Olaniran, Christian. “Operations at Baltimore Coal Terminal Caused Air Pollution in Curtis Bay Community, Study Says.” CBS Baltimore, July 21, 2025. https://www.cbsnews.com/baltimore/news/coal-terminal-curtis-bay-pollution
➔ Heaney, Christopher D., et al. “Air Pollution in Baltimore’s Curtis Bay Community Linked to Nearby Coal Terminal Activities and Wind.” Johns Hopkins Bloomberg School of Public Health, July 21, 2025. https://publichealth.jhu.edu/2025/air-pollution-in-baltimores-curtis-bay-community-linked-to-nearby-coal-terminal-activities-and-wind

Coal Cargo Hazards and Maritime Risk
➔ U.S. Coast Guard. “Stocking Stuffers That Go Boom: Know the Explosion Hazards of Coal.” Marine Safety Alert 07-25, February 13, 2025. https://www.dco.uscg.mil/Portals/9/DCO%20Documents/5p/CG-5PC/INV/Alerts/USCGSA_0725.pdf
➔ Sanders, Neil, and Gitana Røyset. “Coal Cargoes: Avoiding Explosion and Self-Heating.” Gard Insights, December 13, 2023. https://gard.no/insights/coal-cargoes-avoiding-explosion-and-self-heating
➔ Skuld. “Carriage of Coal Cargoes: Self-Heating and Explosion Risks.” Skuld Topics, January 7, 2016. https://www.skuld.com/topics/cargo/solid-bulk/coal-cargoes/carriage-of-coal-cargoes-self-heating-and-explosion-risks

_______________________________________________________________________________________________________________________

Baltimore Harbor Crossings - Roads to the Future article with a photo of the Key Bridge and a photo of the completed widening and reconstruction of I-695 on Sparrows Point.

Original Roads to the Future article Francis Scott Key Bridge (Outer Harbor Crossing)

Sunshine Skyway Disaster - Roads to the Future article highlighting how this was different from the Key Bridge disaster.

Roads to the Future articles:
Bridge-Tunnel Facilities in Virginia
Hampton Roads Area Interstates and Freeways
Monitor-Merrimac Memorial Bridge-Tunnel (I-664)

Copyright © 2025 by Scott Kozel. All rights reserved. Reproduction, reuse, or distribution without permission is prohibited.

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By Scott M. Kozel, Roads to the Future

(Created 9-3-2025, last update 9-9-2025)